I have several clients who offload ships/containers in this manner. Whenever I see this, I immediately go to “that is a PRCS”. The ship/container is for sure a CS, and the fact that we have an engine putting off CO inside the ship/container makes the space a PRCS. I am fortunate enough to have great clients who think about it and have agreed there is a risk in practice. But last month, I was at a facility, and I came across this. Their response, from their lawyer – not a safety professional… “1910.146 does not apply to that, so if you cant show us a Maritime Standard that we are violating, we want this removed from the report.”
What is your take?
The best I could maritime standard I could find is 1917.23 – Hazardous atmospheres and substances (see also ยง1917.2 Hazardous cargo, material, substance or atmosphere) , which leads us to 1917.23 Carbon Monoxide in enclosed spaces. The facility claimed the 40′ deep, open-top container was not “enclosed”. As well they made the point that 1912.2 defines a Confined Space in the maritime industry as:
